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ISO 37001: A New Measuring Stick for Corporate Compliance Programs

The International Organization for Standardization is developing a certifiable international standard for “anti-bribery management systems” that could influence how the US Department of Justice, US Securities and Exchange...more

SEC Charges State Street Employee For Fraudulent Fees

Transition Management is a service offered by securities professionals to pension funds and other investment managers who are changing fund managers, investment managers or making similar transitions and need to make...more

This Week In Securities Litigation

The Commission prevailed at trial this week, securing a favorable verdict after a two week jury trial. The action centered on false statements made by an executive regarding regulatory approvals for the only drug of the...more

DOJ’s New FCPA “Pilot Program” Targets Corporate Officers and Other Individuals

For years, FCPA observers have predicted that the Department of Justice (“DOJ”) will increase its prosecutions of corporate officers and employees for FCPA violations. These predictions have so far proven disputable, as the...more

Dorsey Anti-Corruption Digest - April 2016

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more

Forex Investment Scheme Results in Criminal Charges

Investment fund fraud and Ponzi schemes have become a staple of SEC enforcement. The investment fraud schemes often cross from securities into other areas such as the currency markets. In such instances either the CFTC or the...more

This Week In Securities Litigation

Budget hearings were a focus this week as the Chair of the SEC and Chairman of the CFTC visited Capitol Hill. Both sought substantial increases, requesting more money for technology, inspections and enforcement. While the...more

DOJ's New FCPA Guidance and Pilot Program

On April 5, 2016, in an effort to bolster FCPA Compliance, the Department of Justice issued its "Foreign Corrupt Practices Act Enforcement Plan and Guidance" identifying the following three steps to enhance its FCPA...more

DOJ Launches FCPA Pilot Program to Promote Company Self-Reporting

In a speech delivered last Wednesday by Assistant Attorney General Leslie Caldwell, the Justice Department’s (“DOJ”) Criminal Division announced the launch of a new Foreign Corrupt Practices Act (“FCPA”) “pilot program” that...more

DOJ’s Fraud Section Issues Foreign Corrupt Practices Act Enforcement Plan and Guidance

On April 5, 2016, the Department of Justice’s Fraud Section (“DOJ”) issued its Foreign Corrupt Practices Act (“FCPA”) Enforcement Plan and Guidance (“Guidance”), which announced (1) a more than doubling of DOJ resources...more

This Week In Securities Litigation

The Commission prevailed on a summary judgment motion this week in a case based on an offering fraud. It also filed another settled FCPA action centered on gifts, travel and entertainment provided to healthcare professionals...more

DOJ Announces Prison Sentences of Former Derivatives Traders for LIBOR Manipulation

On March 10, the DOJ announced that U.S. District Judge Jed S. Rakoff sentenced two former derivatives traders for a Netherlands-based bank to prison for their roles in a scheme to manipulate the London Interbank Offered...more

FinCrimes Update - February 2016 Summary, Volume 4, Issue 2

OCC AND FINCEN ASSESS CIVIL MONEY PENALTIES AGAINST FLORIDA-BASED WEALTH MANAGEMENT FIRM FOR BSA VIOLATIONS - On February 25, the OCC, in coordination with FinCEN, announced that it took action against a Florida-based...more

Corporate Investigations & White Collar Defense - February 2016

Eye on the Courts—Recent Opinions and Rulings of Note - Why it matters: From a white collar and securities fraud standpoint, there has been a lot of noteworthy activity in the courts of late. The Supreme Court granted...more

VimpelCom's Global FCPA Settlement - A Multinational Resolution

The U.S. Department of Justice (DOJ), the U.S. Securities and Exchange Commission (SEC) and the Public Prosecution Service of the Netherlands (OM) announced a coordinated criminal and civil Foreign Corrupt Practices Act...more

Key Takeaways From This Year’s Early FCPA Enforcement Actions

February has been a big month for U.S. Foreign Corrupt Practices Act (FCPA) enforcement. It started with the U.S. Securities and Exchange Commission (SEC) quietly resolving a string of relatively small matters. Then, at the...more

This Week In Securities Litigation

At SEC Speaks Chair White noted that the SEC is more than a disclosure agency. In areas like exchange regulation financial standards and investment advisers the Commission engages in substantive regulation, suggesting perhaps...more

SEC Speaks 2016: Enforcement Panels Double Down on Use of Data Analytics

Data collection and analysis continue to impact SEC’s approach to enforcement. The increasing use of data analytics to jump-start investigations and enforcement efforts dominated the panel discussion at this year’s...more

Yates Memo in Action: No Cooperation Credit in FCPA Enforcement for Failing to Disclose Key Facts

A recent case illustrates both the ongoing corruption risks for U.S. companies doing business in developing countries such as China and the Government’s tougher stance on settling white collar crime cases. In this case, the...more

Lessons from DOJ’s FCPA Resolution with PTC China: No Partial Self-Disclosure Credit

In 2015, the Department of Justice (DOJ) made more news for the corporate Foreign Corrupt Practices Act (FCPA) cases that it did not bring than for the two that it did bring: Nine times last year, DOJ declined to join...more

SEC Announces Its First Deferred Prosecution Agreement With an Individual in an FCPA Case

On February 16, 2016, the SEC announced its first ever deferred prosecution agreement (“DPA”) with an individual in a Foreign Corrupt Practices Act (“FCPA”) case. As part of a settlement in which a Massachusetts-based...more

This Week In Securities Litigation

The Commission filed two settled FCPA cases this week. On was resolved with the payment of almost $800 million to the SEC, DOJ and Dutch regulators where about $114 million in bribes were paid. The other centered on the...more

PTC Inc. Reaches $28M Settlement with DOJ and SEC to Resolve China FCPA Allegations

On February 16, 2016, two Chinese subsidiaries of Massachusetts-based software company PTC Inc. (“PTC”) entered into a non-prosecution agreement with the U.S. Department of Justice (“DOJ”) and will pay $14.54 million to...more

Travel, Entertainment, Gifts Yield DOJ, SEC FCPA Charges Again

Travel, entertainment and gifts tied to inadequate controls are recurrent themes in FCPA cases. Many of these cases involve the use of agents and center in China. Each of these recurrent items appear in the most recent FCPA...more

FinCrimes Update - January 2016 Summary, Volume 4, Issue 1

JANUARY FINCRIMES WEBINAR RECAP: 2015 ENFORCEMENT ACTIONS: LESSONS LEARNED FOR REGIONAL AND SUPER-REGIONAL BANKS - On January 28, 2016, BuckleySandler hosted 2015 Enforcement Actions: Lessons Learned for Regional and...more

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